Draft Local Plan Consultation Form 2017
Draft Local Plan Consultation
We are preparing a new Local Plan which will guide development in the district up to 2032. The Draft Local Plan contains planning policies and site allocations, including where new housing and employment development will take place.
You can find all supporting information to this consultation online via www.hart.gov.uk/draft-local-plan or hard copies of the consultation documents are available to view at the Hart District Council Offices, Town and parish council offices and public libraries across the district.
All valid comments (electronic or written) and the name(s) of the respondent will be made publically available. Personal contact details will remain confidential.
We encourage you to respond to our Draft Local Plan consultation using our online form available at www.hart.gov.uk/draft-local-plan-consultation. However if you wish, you can use this word version ofthe response form and email to or post to Planning Policy, Hart District Council, Harlington Way, Fleet, GU51 4AE.
This form contains two comments sections. If you wish to make more than two comments please copy and paste the boxes as required.
All comments must be submitted no later than 5pm on Friday 9 June.
* Indicates a required field.
Response form
Are you a: *
☒ Resident
☐ Business
☐ Agent
☐ Other (i.e. Community interest group)
If Resident please complete:
Name* Click here to enter text.
Address* Click here to enter text.
Phone number Click here to enter text.
Email* Click here to enter text.
If Business please complete:
Name* Click here to enter text.
Organisation* Click here to enter text.
Job title Click here to enter text.
Business address Click here to enter text.
Phone number Click here to enter text.
Email* Click here to enter text.
If Agent please complete:
Agent details
Name* Click here to enter text.
Organisation* Click here to enter text.
Job title Click here to enter text.
Phone number Click here to enter text.
Email* Click here to enter text.
Client details
Name* Click here to enter text.
Organisation Click here to enter text.
Address* Click here to enter text.
If Other please complete:
Please specify Click here to enter text.
Name* Click here to enter text.
Completing details on behalf of Click here to enter text.
Address* Click here to enter text.
Phone number Click here to enter text.
Email* Click here to enter text.
☐ Please tick this box if you do not want to be contacted about Local Plan documents or updates
Comment 1
Please indicate the document and specific page, section or policy and paragraph you are commenting on:
☒ Draft Local Plan: Strategy and Sites
☐ Sustainability Appraisal
Page number/s:* Click here to enter text.
Section/Policy number:* Policy SS1
Paragraph: 77, 95 and 101
Do you support, oppose or have general comments about this part of the document? *
☐ Support
☒ Oppose
☐ Comment
Please provide your comments below: *
I would like to object to the policies SS1 & MG1 and the supporting paragraphs (77, 95 and 101) that say Hart must build 10,185 new dwellings over the plan period 2011-2032.
There are several lines of argument:
· Vastly Over-achieves against Government housing policy
· Strategic Housing Market Assessment target of 8,022 is too high
· Hart’s decision to increase the target by 2,000 dwellings to the target is inappropriate
Vastly over-achieves against Government housing policy
The 2012-based government projections of population and number of households, points to a need of around 215,000 dwellings per annum, compared to recent delivery of 130-170,000 new dwellings each year. It is clear we need to respond to the objective in the National Planning Policy framework to “boost significantly the supply of housing”. To achieve this, it follows thatthe sum of all the housing market assessments across the country should add up to the total expected increase in households, or a little more to give some margin of safety.
It is worth noting that the DCLG forecasts project forwards the recent high level of inward migration to the UK. Government policy and the impact of Brexit is likely to reduce inward migration so, it is likely the 2014-based projections are too high. Moreover, the DCLG forecasts also assume a reduction in average household size.
The 2016 Strategic Housing Market Assessment (SHMA) has arrived at a ‘need’ of some 8,022 new dwellings over the plan period.
For Hart, the raw 2014-based DCLG forecasts, as opposed to the 2012-based forecasts used in the SHMA, would result in a starting point for housing need of c. 4,473 new houses (see Figure 6 of the SHMA). Hart’s overall housing requirement as defined in the SHMA is some 79% above the starting point. The 10,185-target used in the Local Plan is some 127% above this basic requirement.
If this were applied across the whole country, then we would be allocating land and allowing the building of some 488,000 new dwellings each year, far above the national requirement. This goes against latest planning guidance that states that housing need should be “principally understood as a measure of future demand rather than aspiration”. Analysis of five other housing needs assessmentsof planning authorities across Hampshire, Oxfordshire, Surrey and Berkshire reveals an average housing uplift on the starting point projections of around 42%.
There might be some justification if this process had resulted in more house building. But it is clear from a recentHouse of Lords reportthat it has not:
Nevertheless, we see the gap between planning permissions and housing completions as a fundamental one in respect of securing increased housing supply. In a climate where over240,000 homes a year are being granted planning permission, it is a fundamental failure of the development system that over 100,000 fewer homes are actually being built. This situation must be addressed.
We believe that the Government must consider measures to help accelerate the delivery of housing on sites with planning permission, such as permitting the charge of equivalent council tax rates when development has not commenced after a specified period of time, subject to safeguards when there are genuine reasons to prevent the development proceeding.
This is borne out bylocal experience, where, as of 1 April 2016 there were over3,000 unimplemented planning permissions, with over 1,000 of those from 2013 or earlier.
The unintended consequence of this policy is effectively state-sponsored profiteering on behalf of the major housebuilders. It is plainly ridiculous that the housing target in Hart’s SHMA and the SHMAs of neighbouring areas are massively above the requirement suggested by demographic change, immigration and changes to household size. Accordingly, the housing target and the Local Plan should be adjusted downwards to more realistic levels.
Strategic Housing Market Assessment is too high
Following on from the above, we can now analyse the reasons why the SHMA has arrived at a target that is too high. We can also arrive at a more realistic figure.
Inappropriate Starting Point
First, the starting point used is the 2012-based DCLG forecasts, or around 5,334 dwellings over the plan period. The starting point should be revised downwards by using the more up to date 2014-based forecasts which would result in a starting point of 4,473 dwellings.
The SHMA then uplifts the starting point in response to market signals to provide more housing for what are termed suppressed households. These are, for instance younger people in the 25-34 age bracket who are still living with their parents and are unable to afford to form their own household. Almost by definition these people cannot afford to rent their own accommodation or buy their own house. The SHMA suggests a 15% uplift on the start-point. Even though some element of household size reduction is included in the DCLG forecasts. We would agree with this and increase the need by 671 units to arrive at a total housing need of 5,144. However, we would insist that these units are delivered as social rented housing. The proposed Hart Development Corporation could be an appropriate vehicle to deliver these homes, or partnerships with local Housing Associations.
Affordable Housing Uplift
The SHMA then makes a further upward adjustment for affordable housing. This is to help those able to afford to rent, but not able to access home ownership. By definition, these people are already housed. It is therefore difficult to see how building more houses will assist these people. If they can afford to rent, then it is very likely that they can afford to service a mortgage, but cannot afford a deposit. The way to help these people is with shared ownership or ‘Help to Buy’ schemes. It is also worth noting that some of these people may be taking an entirely rational decision to rent and not buy because they think property prices are too high and thus represent a poor investment when assessing potential future returns.
The only plausible reason to build more houses to help these people would be that it would lead to a general fall in house prices. This is a false premise as discussed by Ian Mulheirn of Oxford Economics here.
The extent that we do see high house prices as a policy priority in and of themselves (e.g. for wealth distributional reasons), this is not a problem that will be solved by any plausible amount of new supply. Many econometric studies in the UK (see page 43herefor a comparison of results) have concluded that a 1 percent increase in the housing stock per household will only cut prices by at most 2 percent. Consequently, even if we were to add 300k new houses per year (about 150k in excess of household formation, approaching 0.5 percent of current stock), this would only lower prices by about 1 percent per year. This is peanuts in the context of price rises over the past 20 years….
Building many more houses that people want to live in is a dangerous route to go down, as Spain and Ireland can attest. For comparison, Ireland had an estimated surplus of dwellings over households of around 14 percent on the eve of the financial crisis (which among other things proves that households don’t just form because there are vacant houses). This building mania was something like the equivalent, relative to stock, of the UK adding 1 million new dwellings per year from 2002–11. But even this didn’t do anything noticeable to rein in Ireland’s property market during the boom, with prices rising by a fair amount more than the UK’s. A similar story can be told in Spain.
Therefore, the affordable housing need should be seen as the proportion of overall housing need that should be built as ‘affordable’ units. The SHMA adds 504 extra affordable units to the total housing requirement. However, this 504 units represents only 11.2% of the 4,473 raw housing need. Hart’s target is to build 40% affordable housing and recent delivery has averaged just over 20%. If this were to continue and the housing target were revised to start at 4,473, then around 900 affordable homes would be delivered in addition to the 671 social rented units identified above.
Jobs Growth Adjustment
Finally, the SHMA makes a further increase to the housing target to take account of future jobs growth. There are several issues with this adjustment.
First, the jobs forecasts made by outside bodies are simply taken as read with no analysis or critique. We know they are wrong simply by looking at the forecasts in Appendix D. These show the number of jobs in 2015 to be in the range 158-174K depending upon which forecasting house is used. However, the latest BRES data for 2015 shows the total number of jobs to be 143K for the Housing market area, a shortfall of 15-30,000, or almost all the projected job growth.
Second, the projection of 1,200 jobs per annum is far more than the 1998-2015 average of 1,029, and the report itself states that it is unrealistic to expect recent jobs growth to continue at the same rate.
Third, the SHMA uses a very circular argument to account for the number of jobs. The argument is: the forecasts say you should have 1,200 extra jobs per annum in the HMA. They then acknowledge the forecasts are unachievable because there won’t be enough people of working age to fill those jobs.
They then decide we will need to import some extra people and those people will need houses. The SHMA then acknowledges that most of these people will work outside the district. This is borne out by the M3 LEP Strategic Plan, which does not identify any part of Hart as either a ‘Growth Town’ or a ‘Step-Up Town’, so will be starved of investment. Moreover, the Employment Land Review (ELR) describes Hart’s office space as:
There appears to be an over-supply of lower grade stock with concentrations of dated, larger footprint, stock to the north of the town centre, specifically at Ancells Business Park, which is currently experiencing relatively high levels of vacancy.
Hook office space similarly experiences high vacancy rates and there is strong interest in office to residential conversion.